ML20133C502

Insp Repts 50-424/85-40 & 50-425/85-31 on 850819-23. Violation Noted:Failure to Follow Procedures for Control of Welding & Failure to Protect Permanent Plant Equipment

ML20133C502
Person / Time
Site:	Vogtle
Issue date:	09/23/1985
From:	Blake J, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133C487	List: ML20133C482 ML20133C488 ML20133C502
References
50-424-85-40, 50-425-85-31, NUDOCS 8510070383
Download: ML20133C502 (12)

See also: IR 05000424/1985040

Text

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UNITED STATES

/gk% ErgD.o ~

NUCLEAR REGULATORY COMMISSION

[" p REGION 18

101 MARIETTA STREET N.W.

$ j

• 't ATLANTA, GEORGI A 30323

\...... /

Report Nos.: 50-424/85-40 and 50-425/85-31

Licensee: Georgia Power Company

P. O. Box-4545

Atlanta, GA 30302

- Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109

Facility Name: Vogtle 1 and 2

Inspection Condu ed: August 19 - 23, 1985

Inspector:

G.

A r c4

stro

w T//G/8[

Da e ' Signed

Approved by.

J. .

v _

lakT, Sectiori Chief

kDate'

87Signed

W

M er als and Processes Section

vi ion of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection involved 22 inspector-hours on site

in the areas of employee concerns, housekeeping (Units 1 and 2), material control

(Units 1 and 2), reactor coolant pressure boundary piping (Unit 1), safety-

related ping (Unit 1), safety-related components, and licensee identified items

(50.55(e .

Results: Two violations were identified - Failure to Follow Procedures for

Control of Welding - paragraphs 7.b(1) and 7.b(3); and Failure to Protect Permanent

Plant Equipment - paragraph 9.

$$g4 PDR

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REPORT DETAILS

1. Licensee Employees Contacted

• W. T. Nickerson, Deputy Project General Manager

• G. Bockhold, General Manager, Vogtle Nuclear Operations Division

• C. W. Hayes, Vogtle Quality Assurance (QA) Manager

• E. D. Groover, QA Site Manager, Conrtruction

• C. E. Belflower, QA Site Manager, Operations

• D. M. Fiquett, Unit 2 Field Construction Manager

• W. Wagner, Quality Control (QC) Superintendent-0peration

• M. Bellamy, Initial Test Manager, Operations

• M. S. Hairston, Regulatory Compliance Associate Engineer

• G. A. McCarley, Project Compliance Coordinator

Other licensee employees contacted included construction craftsmen, engineers,

t ar' nicians, operators, mechanics, security force members, and office

p.. ,rnnel.

Other Organizations

• D. L. Kinnsch, Project Field Engineer, Bechtel Power Company (BPC)

• J. Mamon, Quality Engineer, BPC

• G. H. Fredy, Technical Specialist, BPC

• J. Steele, " Manager, Pullman Power Products (PPP)

• T. C. Clark, Assistant QA Manager, PPP

• A. Holtz, V-SAMU Piping Systems As-Built Engineer, Westinghouse

• C. S. McCall, Construction Supervisor, Oglethorpe Power Company

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on August 23, 1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee.

(0 pen) Inspector Followup Item 424/85-40-01, 425/85-31-01 - Assurance of

Necessary Minimum Clearances for Installed Piping, paragraph 5.

(0 pen) Unresolved Item 424/85-40-02, 425/85-31-02 - Assurance of Adequate

Backpurge for Welding Stainless Steel Piping, paragraph 7.b.(1).

(0 pen) Violation 424/85-40-03, 425/85-31-03 - Failure to Follow Procedures

for Control of Welding, paragraphs 7.b (1) and 7.b.(3).

(0 pen) Violation 424/85-40-04 - Failure to Protect Permanent Plant Equip-

ment, paragraph 9.

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The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

Unresolved items are matters about which more information is required to

detennine whether they are acceptable or may involve violations or devia-

tions. One new unresolved item identified during this inspection is

discussed in paragraph 7.b.(1).

5. Independent Inspection Effort

ilousekeeping (548348), Material Identification and Control (42902B) and

Miterial Control (429408)

The inspector conducted a general inspection of Units 1 and 2 containments

and the reactor auxiliary building to observe activities such as house-

keeping, material identification and control; material control, and storage.

During the above inspection the inspector noted apparent clearance problems

between installed piping and Unit 1 containment pipe racks. There appeared

to be potential for contact between the 12" x 12" x 6" Reducing Tee In

Reactor Coolant Line 1-k4-1201-036-01 and the top of Column 8 in rack R0001.

There also appeared to be potential for contact on other locations between

the racks and pipe clamps which will be used to attach snubbers and struts.

Final alignment of the clamps will reduce the present clearances in these

locations.

Cognizant licensee personnel informed the inspector that BPC was in process

of revising specification X4Z01, Division P3 to include minimum separation

distances between piping and other obstructions. A general minimum separa-

tion of 1" in the direction of the obstruction will be imposed and any

deviations will require evaluation and acceptance by the project engineer.

The inspector was also informed that these requirements are incorporated in

the latest revision of PPP procedure IX-3, which is nearing final approval.

Cognizant licensee personnel also informed the inspector that a Deviation

Report (DR) would be issued in response to inadequate separation at

Column 8 of Rack R0001 and that additional generic corrective actions will

be required to assure adequate implementation of the new general 1" minimum

separation criteria. The inspector informed cognizant licensee personnel

that NRC concern on this matter will be identified as Inspector Followup

Item 424/85-40-01, 425/85-31-01 - Assurance of Necessary Minimum Clearances

for Installed Piping.

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6. Employee Concerns

NRC had previously received an employee concern regarding inadequate

qualification of a PPP welder who was making heavy section weldments on

Unit 1 containment pipe racks. The inspector reviewed pertinent qualifica-

tion data for the welder in question. The inadequate qualification had been

identified on February 16, 1984, and DR No. PP-4123 issued to accomplish

removal of weld metal to the thickness allowed and rewelding by another

welder qualified to unlimited thickness. The original welder completed

additional testing to qualify for unlimited thickness welding on

February 23, 1984. Af ter additional record review by PPP personnel, six

additional welds were identified as having been incorrectly complated by the

welder involved prior to February 23, 1984. DR No. PP-11533 was issued to

accomplish adequate engineering disposition of the six welds involved.

The inspector had previously conducted final visual inspection and review of

necessary wcld inspection and welder qualification data for several similar

welds completed by the welder in question after February 23, 1984 (Inspec-

tion Report Nos. 424, 425/84-30 and 424, 425/85-03). No deficiencies

related to welder performance or qualification were identified.

The inspector also examined revisions to PPP Procedures VI-5 " Control of

Process Sheets and Weld Rod Requisition" and VIII-3 " Control of Welding

Materials (Field)" which clarify requirements for check of required welder

qualification to the thickness involved during issuance of the weld metal

requisition form. Cognizant licensee personnel informed the inspector that

a records review had not identified any other instances of inadequate

qualifications.

The inepvtor concluded that licensee actions had been sufficient to address

this e p jee concern and this matter is considered closed.

7. Reactor Coolant Pressure Boundary Piping (Unit 1)

The inspector examined welding and nonwelding activities for reactor coolant

pressure boundary piping to determine whether applicable code and procedure

requirements were being met. The applicable code for rector coolant

pressure boundary piping is the ASME Boiler and Pressure Vessel Code,

Section III,1977 Edition with Addenda through W77,

a. Review of Nonwelding Quality Records (49055)

The inspector selected various reactor coolant piping components (e.g.,

pipe, fittings and welded-in components) for review of pertinent

records to determine conformance with procurement, storage and

installation specifications and QA/QC site procedures.

Records of the following items were selected for review to ascertain

whether they (records) were in conformance with applicable requirements

relative to the following areas: material test reports / certifications;

vendor supplied NDE reports; Nuclear Steam Service Supply quality

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releases; site receipt inspections; storage; installation; and vendor

nonconformance reports.

Item Heat / Control No.

2" Sched. 160 pipe 466976

2' x 2" x 1" sched. 160 TEE E7328

Within the areas inspected, no violations or deviations were

identified.

b. Welding Activities

(1) Observation of Work (55173) (Unit 1)

The inspector observed in-process welding activities of reactor

coolant piping field welds inside of containment as described

below to determine whether applicable code and procedure require-

ments were being met.

The below listed repair welds were examined in-process to verify

work conducted in accordance with traveler, welder identification

and location, welding procedures, WPS assignment, welding

technique and sequence, materials identify, weld geometry, fit-up;

temporary attachments, gas purging, preheat, electrical

characteristics, shielding gas, welding equipment condition,

interpass temperature, interpass cleaning, process control

systems, qualifications of inspection personnel, and weld history

records.

ISO Welds Size Status

1K4-1201-027-01 R/6 193-W-109A* 2" Fit-up & Tack

IX4DL4020 R/0 059-W-04-R1 6" Fit-up & Tack

• Previous weld completely removed

During the above inspection the inspector informed cognizant

licensee personnel of the continuing NRC concern regarding the

assurance of adequate backpurge when completing stainless steel

welds. Observations concerning weld 193-W-109A are as follows:

Backpurge was more critical than normal since this was a

repair weld.

The first tack had been completed prior to the inspector's

arrival but no oxygen analyzer was present.

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The welder was uncertain of either the backpurge time

requirements or the 0.5% (or less) oxygen requirements for

adequate backpurge as incorporated in Section 4.0 of the PPP

General Welding Standard (GWS-III/I Rev. 3/28/84).

The technique sheet for the controlling welding procedure

specification (WPS No. 29-III/I-6-08-1) was not the latest

revision which includes clarification of the 0.5% (or less)

oxygen requirement.

After an oxygen analyzer had been secured, approximately 40

minutes were required to reach an acceptable 0.5% oxygen

limit due to inefficient placement of tape on the joint

involved.

The repair had been required due to root defects on the

original welds involved.

QC inspectors are not required to inspect for assurance of

adequate backpurge except on a random basis. (The welder

involved could not remember any occasion during which he had

been so monitored.)

Due to the above observations, the inspector conducted a random

survey of several welders who normally weld stainless steel pipe.

Approximately half of the welders were uncertain of the specifics

regarding backpurge requirements. Also, technique sheets for

other WPSs which had been issued from the "doublewide" welding

materials distribution center (WMDC) were not the latest revisions

which include clarification on backpurge requirements. The

inspector noted that failure to distribute the latest technique

sheets was a lack of conformance to paragraph 1.4 of the PPP

General Welding Standard (GWS.III/I) 12/14/84 revision. This is

another example of violation 424/85-40-03, 425/85-31-03 and is

further reported in paragraph 7.b.(3). The inspector also noted

that NRC concern regarding adequate backpurge had been discussed

with cognizant licensee personnel during previous inspections wit'

special emphasis given to the need for transmitting clarified

infonnation on backpurge to the welders involved. The inspector

further noted that code Class 3 welds do not receive

nondestructive root examination and therefore adequate backpurge

's the major assurance against unidentified root defects. The

inspector informed cognizant licensee personnel that NRC's concern

regarding this matter will be identified as Unresolved Item

424/85-40-02, 425/85-31-02 - Assurance of Adequate Backpurge for

Welding Stainless Steel Piping.

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(2) WelderQualification(55177)

The inspector reviewed the PPP program for qualification of

welders and welding operators for compliance with QA procedures

and ASME Code requirements.

The following welder qualification status records and " Records of

Performance Qualification Test" were reviewed relative to the weld

joints-listed in paragraph 7.b(1) and 8.b(1).

Welder Symbol WPS.

CW-1 29-III/I-8-08-1

DA-1 38-III/I-8-KI-1

DV-1 27-III/I-8-08-12

GF-1 32-III/I-8-12

(3) Welding Filler Material Control (55172)

The inspector reviewed the PPP program for control of welding

materials to determine whether materials were being purchased,

accepted, stored and handled in accordance with QA procedures and

applicable c'de requirements. The following specific areas were

examined.

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- Purchasing, receiving, storing, and distribution and handling

procedures; material identification; and inspection of

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welding material issuing stations.

- Welding material purchasing and receiving records for the

following material applicable to the weld joints listed in

paragraphs 7.b.(1) and 8.b.(1) were reviewed for conformance

with applicable procedures and code requirements.

l bge Size. Heat, Lot, Batch /No.

ER308L 1/16" x 36" 26245

ER308L 3/32" x 36" 05394

ER308L 1/8" x 36" 05394

During the above inspection the inspector observed apparent

inconsistencies in the oven check daily log for the doublewide

,

WMOC. On August 20, 1985, the inspector observed that stationary

i holding ovens nos. 20, 25, and 26 were turned off, were at ambient ,

temperature, and that all electrodes had been removed. However,

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the daily log for August 20, listed 300*F, 300*F, and 260'F,  !

respectively, for these ovens. Second shift WMDC personnel were

unable to explain the apparent discrepancy and stated that the log ,

was the responsibility of first shift personnel. l

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' The inspector responded that paragraph 7.2.1.G of PPP procedure

VIII-3 " Control 'of Welding Materials (Field)" required that

stationary oven holding temperature indicators be read daily to

verify that holding oven temperatures were between 250*F and

-400 F.. The intent is to assure that electrodes stored in ovens

are not issued if oven temperatures are less than 250 F and that

. the actual oven temperature was to be listed for the oven

involved.

On August 21, 1985,- temperatures of 300 F, 300 F and 285 F were

logged for oven nos. 20, 25, and 28. After investigation,

cognizant licensee personnel informed the inspector that the ovens

had been turned off the morning of August 20, 1985, and sufficient

time had. elapsed for them to cool to ambient prior to the

inspector's initial observations. The August 21, 1985, entrees

had been made without an actual observation of the oven

' temperature gages. The inspector informed the licensee that this

matter and the failure to distribute proper welding technique

sheets reported in paragraph 7.b.(1) were considered a lack of

conformance to 10 CFR 50, Appendix B, Criterion V as implemented

by PPP Procedures VIII-3 and GWS III/I. These matters will be

identified as Violation 424/85-40-03, 425/85-31-03 - Failure to

Follow Procedures for Control of Welding. The inspector also

noted that the failure to follow procedure VIII-3 was considered a

repeat of violation 424, 425/85-14-02 for which corrective action

had been reported as completed by June 30, 1985.

Within ' the areas inspected, one violation, as noted above, was

identified. No deviations were identified.

8. Safety-Related Piping (Unit 1)

The inspector examined welding and nonwelding activities for safety-related

piping to detennine whether applicable code and procedure requirements were

being met. The' applicable code for safety-related piping is the ASME Boiler

and Pressure Vessel Code,Section III,1977 Edition with Addenda through

i W77.

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a. Review of Nonwelding Quality Records (49065)

The inspector selected various safety-related piping components

(e.g., pipe, fittings and welded-in components) for review of pertinent

records to determine conformance with procurement, storage and

,

installation specifications and QA/QC site procedures.

' "

Records of the following items were selected for review to ascertain

i ~w hether they (records) were in conformance with applicable requirements

[ relative to the following areas: material test reports / certifications;

! vendor supplied NDE reports; Nuclear Steam Service Supply quality

release; site receipt inspections; storage; installation; vendor

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nonconformance reports.

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Item Heat / Control No. System

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3/4" 1500# Sched. 160 ABOC Chemical Volume and

i SW Flange Control System (CVCS)

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3/4" Sched. 160 pipe 464057 CVCS

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Within the areas inspected, no violations or deviations were

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i identified.

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b. Welding Activities

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(1) Observation of Work (55183) (Unit 1) i

The inspector observed in-process welding activities of safety

injection piping field welds inside of containment as described

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below to determine whether applicable code and procedure require- l'

. ments were being met.

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! The below listed welds are examined in-process to verify work

!

conducted in accordance with traveler, welder identification and

[ location, welding procedures, WPS assignment, welding technique

) and sequence, materials identity, weld geometry, fit-up; temporary  ;

j attachments, gas purging, preheat, electrical characteristics,

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shielding gas, welding equipment condition, interpass temperature,

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interpass cleaning, process control systems, qualifications of

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inspection personnel, and weld history records.

l ISO Weld Size Status

$ 1K4-1208-043-02 R/9 374-W-101 3/4" ist. Pass

{ 1K4-1208-020-02 R/6 020-W-145A 3/4" Fit-up

! The following inspector qualification status records and QA/QC

l Inspector Qualification / Certification records were reviewed

j relative to inspection of the weld joints listed above.

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! Inspector Type of Certification

PEM-PPP VT-II

(2) Welder Qualification (551878)(Unit 1)

The inspector reviewed PPP's program for qualification of welders.

The applicable procedure is II-8, Welder Performance Procedure:

(12/14/84).

The following specific areas were examined:

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Procedures for qualification of welders

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- Procedures for maintaining continuity of status records

- Review of welder qualification status records and Records of

performance Qualification Tests, relative to the weld joints

listed in' paragraph 8.b.(1) above is documented in paragraph

7.b.(2).

(3) Welding Material Control (551828)(Units 1 and 2)

The welding material control inspection documented in paragraph

7.b(3) for reactor coolant piping also applies to safety-related

piping.

Within the -areas inspected, one violation, as reported in

- paragraph 7.b.(3),wasidentified. No deviations were identified.

9.- Safety-Related Components Observation of Work (50073)

The inspector examined Train A nuclear service cooling water pumps (P4-001,

P4-003, and P4-005) to determine whether:

.

.

Installation requirements were met such as: proper location, place-

i ment, orientation, alignment, mounting (torquing of bolts and expansion

anchors), flow direction, tolerances, and expansion clearances.

Precautions were taken to prevent damage during placement / mounting.

. Installation and inspection records were prepared and maintained. j

Maintenance inspection activities : including scope and frequency are

being performed according to instructions.

. Protection is being provided in accordance with manufacturer's instruc-

tions and/or established procedures as required, including protection

-against adverse temperature, humidity, flooding, and foreign mater:als

such as dirt, dust, bottles, cans, and general debris.

• - Lubrication, rotation, and electrical resistance checks are being

performed as required.

Records are being maintained as to the status of installed components.

Appropriate stamps, tags, markings, etc. are in use to prevent over-

sight of required inspections, completion of tests, acceptance, and the

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prevention of inadvertent operation.

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During the above inspection the inspector observed that pump motor heaters

were not energized and that pump motor internals were at ambient tempera-

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.ture. Cognizant licensee personnel informed the inspector that adequate

protection of pump motor coil windings required that heaters be continuously

energized when the pump motor was not running. Also, that the permanent

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electrical connections to the motors had been completed with exception of

the heaters which had been fed from a temporary circuit. The inspector

observed that the temporary circuit involved appeared to have caused

interference with installation of hanger VI-1202-033-H004. Associated

quality data for the hanger indicated Quality Control (QC) inspection of the

NF code welds on July 16, 1985, and final inspection of the hanger

installation on August 14, 1985. Therefore, indications were that the

heaters had been de-energized for approximately one month.

Cognizant licensee personnel provided the inspector with copies of plant

maintenance work orders (PM0s) nos.18503926 (pump P4-001),18503952 (pump

P4-005) and 18503914 (pump P4-003), and stated that these PM0s were the

record for the last maintenance checks completed. PM0 no. 18503926 was

initiated on July 9,1985, and actual maintenance work completed on July 21,

1985. Final QC close-out approval occurred on August 9,1985. PM0 nos.

1803952 and 18503914 were initiated on June 24, 1985, and actual maintenance

work completed on July 21, 1985. Final QC close-out approval occurred on

August 13, 1985. The preoperational maintenance cards for all PM0s

indicated that the check for heater energization was not applicable. The

inspector noted that this check had been required on the equipment

maintenance storage list (EMSL) cards used during construction and that the

requirement originated from guidance in General Electric (GE) manual

GEH-3292C (page 3) that "the temperature of the windings should always be

maintained a few degrees above the temperature of the surrounding air."

Also, that Georgia Puwer Company (GPC) Nuclear Operations Procedure No.

20015-C, Rev. 2, required in paragraph 4.5.2 that "preoperational

maintenance will be consistent with preventive and storage maintenance

identified and performed by construction personnel."

Further, that Section 4.5.3 allows the nuclear operations test supervisor to

delete or add requirements provided a preoperational change request card was

prepared and approved by the respective maintenance supervisor in accordance

with Section 3.6.b. Neither the required preoperational change request

cards nor explanatiori of the deviation from EMSL criteria were provided to

the inspector during this inspection.

Subsequent to the inspection, the inspector received copies of preoperational

maintenance cards for PM0's Nos. 18504636 (pump P4-001), 18506356 (pump P4-005),

and 18506730 (pump P4-003) for maintenance work completed on August 12-13, 1985.

Requirements were that pump motor heaters be energized or that heat trace tape

be installed and energized. Notes indicate that the test supervisor was

informed that pump motor heaters were not energized on August 12 and

August 13, 1985. However, no heat trace tape was installed and heater

energization had not occurred by August 22, 1985.

The above clearly establishes that preventative maintenance inspection

procedures were inadequate to prevent damage or deterioration of equipment.

Failure to establish adequate measures to control storage and preservation

of equipment in accordance with work and inspection instructions to prevent

damage or deterioration is in violation of 10 CFR 50, Appendix B, Criterion 13.

This matter is identified as violation 424/85-40-04. Failure to protect

permanent plant equipment.

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10. Licensee Identified Items (92700)

Prior to the inspection, the licensee identified the following items under

10CFR50.55(e):

(Closed) Item 424/CDR 84-66, Containment Pipe-Rack Welds

On July 20, 1984, the licensee notified Region II of a 50.55(e) item

involving cracks in Unit 1 containment pipe-rack welds. The final report

was submitted on October 17, 1984.

The proposed corrective action plan (DER-061) was reviewed during previous

inspections and concerns documented in Inspection Reports 424/84-30,

424/84-36, and 424/85-03.

Resolution of those concerns were documented in Inspection Report

424/85-08. However this item has remained open pending additional assess-

ment of DER-061.

The inspector conducted additional discussions with licensee representa-

tives, reviewed supporting documentation, and observed representative

samples of work completed to DER-061. The majority of work necessary to

accomplish corrective action has been completed. Remaining inspection and

welding activities scheduled for completion under DER-061 provide assurance

that all NRC concerns have been adequately addressed. This item is

considered closed.

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